Gibson v. Superintendent of New Jersey Department of Law & Public Safety-Division of State Police’s Empirical Analysis
411 F.3d 427 · 2005
Citation profile
9 federal appellate · 10 district ·
How this case has been cited
Cited by 83 later decisions (1 by the Supreme Court) — most recently November 2021 · most notably Dique v. New Jersey State Police (2010), United States v. Delfin-Colina (2006)
9 federal appellate · 10 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Brady v. State of Maryland · Illinois v. Gates · Wong Sun v. United States · United States v. Leon · United States v. Bagley
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 83 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although this Court held in United States v. Perdomo, 929 F.2d [at 970], that evidence in the hands of the police could be imputed to the prosecutor, the Supreme Court did not settle this matter until 1995 when it decided Kyles v. Whitley, 514 U.S. at 437 , 115 S.Ct. 1555 , (“[T]he individual prosecutor has a duty to learn of any favorable evidence known to the others acting on the government’s behalf in the ease, including the police.”). More importantly, the related duty of the police to disclose information to the prosecutor was not widely addressed until later. Even in 2000, this Court was only able to assume that police officers “have an affirmative duty to disclose exculpatory evidence to an accused if only by informing the prosecutor that the evidence exists.” Smith v. Holtz, 210 F.3d 186 , 197 n.14 (3d Cir. 2000). Because such a right was not clearly established in this Circuit at the time of Gibson’s conviction, Troopers Pennypacker and Reilly are entitled to qualified immunity with regard to their failure to inform the prosecutor of Brady material.”
2 later decisions quote this exact passage · from the dissent“affirmatively conceal material evidence from the prosecutor”
2 later decisions quote this exact passage · from the dissent“Within the federal system, for example, we have said that the United States Attorney is “the representative not of an ordinary party to a controversy, but of a sovereignty whose obligation to govern impartially is as compelling as its obligation to govern at all; and whose interest, therefore, in a criminal prosecution is not that it shall win a case, but that justice shall be done.” Berger v. United States, 295 U.S. 78, 88 [ 55 S.Ct. 629 , 79 L.Ed. 1314 ] (1935).”
1 later decision quote this exact passage · from the dissent
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.